Toy balloon tariff classification: functional heading prevails over residual rubber and festive article headings, supporting penalties for deliberate ...
Customs valuation using comparable contemporaneous imports can displace declared value, while missing speaking orders require pursuit before competent...
Foreign customs declarations and importer admissions established undervaluation, supporting sequential value redetermination, differential duty, and m...
Customs seizure safeguards prevent detention-based limitation avoidance and invalidate provisional release conditions for imported vehicles under an i...
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The Appellate Tribunal examined Transfer Pricing Adjustment disallowing cost of support services. The cost allocation key based on 'headcount' was accepted by the Transfer Pricing Officer (TPO) as at Arm's Length Price (ALP) u/s 92CA(3) of the Act. The TPO's role is to ensure pricing is at ALP. Documents were submitted and findings from survey proceedings were available to the TPO. Consistency was maintained as no adjustments were made in prior years. The allocation key should not be disturbed. Regarding depreciation on intangible assets, the Tribunal directed the AO to grant depreciation as per previous rulings in the assessee's favor.
The Appellate Tribunal examined Transfer Pricing Adjustment disallowing cost of support services. The cost allocation key based on 'headcount' was accepted by the Transfer Pricing Officer (TPO) as at Arm's Length Price (ALP) u/s 92CA(3) of the Act. The TPO's role is to ensure pricing is at ALP. Documents were submitted and findings from survey proceedings were available to the TPO. Consistency was maintained as no adjustments were made in prior years. The allocation key should not be disturbed. Regarding depreciation on intangible assets, the Tribunal directed the AO to grant depreciation as per previous rulings in the assessee's favor.
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